Your Privacy Matters to Us

Introduction

Hook (hereinafter referred to as "Hook", "we", "us", or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our platform (either website, mobile application and services).

It also applies to all data subjects who access or use our platforms and it is designed in compliance with the Nigeria Data Protection Regulation (NDPR) 2019, the General Data Protection Regulation (GDPR), and other applicable data protection laws as well as other relevant global privacy standards.

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1. Consent

By using our website or services, you provide explicit consent to the terms of this Privacy Policy and agree to our collection, processing, and storage of your personal data in accordance with applicable laws. You may withdraw your consent at any time by contacting our Data Protection Officer (DPO) or any executive member of Hook's management as provided below. Withdrawal of consent does not affect the lawfulness of data processing based on consent before its withdrawal.

We may amend this Privacy Policy at any time by posting a revised version on any of our platforms (website, mobile application & services). The revised version will be effective 7-days after publication.

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2. Information We Collect

We collect various categories of data from and about users of our services upon onboarding and in the course of carrying out high volume transactions:

a. Personal Information:

• Full name.
• Contact details (email, phone number).
• Identity verification data (Government-issued ID, facial recognition data, biometrics, etc.).
• Financial data (bank account, wallet addresses).

b. Technical and Usage Data:

• IP address, browser type, device identifiers.
• Location data (via IP or device).
• Log data and cookies.
• Transaction history (crypto/fiat-related activities).
• Biometric data (if required for KYC/AML verification).

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, email address, and telephone number.

A. How We Collect Your Data:

• When you register or log into your account via any of our platforms.
• When you transact or interact with our services.
• From cookies or similar technologies.
• From third-party service providers and partners.

B. How We Use Your Information

We use the information supplied in various ways, as follows to:

• Operate, and maintain our website.
• Authenticate user(s) identity.
• Provide Services and process transactions.
• Improve, personalize, and expand our website.
• Understand and analyze how you use our website.
• Develop new products, services, features, and functionality.
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes.
• Send you emails.
• Detect and prevent fraud, abuse and unauthorized access.
• Improve user experience and personalize content.
• Ensure legal and regulatory compliance.

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C. Legal Basis for Processing

We rely on several lawful bases for processing your personal data:

• Consent – for marketing or other optional services.
• Contractual necessity – to provide services you request.
• Legal obligation – for KYC/AML compliance and other statutory duties.
• Legitimate interest – for service improvement, fraud detection and customer support.

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D. Data Retention

We retain your personal data only for as long as necessary to provide the services you have requested, or as required by law. For example:

• Account information – retained until you close your account or for a certain period with extensions as needed for dispute resolution or compliance.
• Transaction data – detained per regulatory timelines depending on jurisdiction usually for a period not less than 3 years.
• Log data – retained for 30 – 90 days for security and analytics purposes, after which it is deleted or anonymized.

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3. Data Protection Rights

We would like to make sure users are fully aware of all their data protection rights. Under the NDPR every user is entitled to the following:

• The right to be informed about the collection and processing of user(s) personal data and its use.
• The right to lodge a complaint or submit a request to a data processor or a supervisory authority within the company in order to exercise your legal rights.
• The right to access information concerning the personal data that you have provided to a data processor or any supervisory authority, without cost, unless public policy or other regulations require otherwise.
• The right of user(s) to access, update or correct personal data.
• The right to object to or withdraw consent.
• The right to receive your data in a portable format.
• The right to remedy upon breach of your privacy rights.
• The right to object to or limit the processing of user(s) personal data.
• The right to be informed if your personal data is being processed for additional purposes beyond what was originally stated at the time of collection.
• The right to be informed about the transfer of your personal data to another country.
• The right to request deletion of your personal data.
• The right to submit a complaint to relevant authorities.

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4. Data Security

We implement technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

• End-to-end encryption.
• Multi-factor authentication.
• Firewalls and anti-virus software.
• Periodic security audits and penetration tests.

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5. Cookie Information

Our website uses cookies to improve user experience and to help us make our website better. Cookies are small files that are placed on your device when you visit a website. They help us understand how users interact with our website, and they can also be used to remember your preferences and settings.

We do not use cookies to collect personal information about you without your consent. We also do not share any cookie data with third parties for advertising purposes.

By using our website, you consent to our use of cookies in accordance with this policy. You can choose to accept or decline cookies at any time by modifying your browser settings. However, please note that you may manage your cookie preferences via your browser settings but if you disable cookies, some features of our website may not function properly.

If you have any questions about our use of cookies, please contact us using the contact details provided in this Privacy Policy.

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6. Sharing and Disclosure of Data

We do not sell or rent your personal data however, we may disclose your data to:

• Regulatory authorities upon legal request.
• Third-party service providers (KYC, cloud hosting, analytics) under strict confidentiality agreements.
• Affiliates and partners under legitimate business interests.

We ensure data sharing aligns with applicable legal safeguards and standard contractual clauses.

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8. Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Hook does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

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Contact Us

At Hook, we are committed to protecting your privacy and handling your personal data with transparency and care. By using our services, you agree to the terms outlined in this Privacy Policy. For any inquiries or concerns regarding your data, please contact our Compliance Team.

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us at:

• ✉️ help@hook.ng
• 📱 +234 901 931 2249